Our letter to the RSA (finished letter)

peasant

This is where our letter to the RSA will take shape as the points from the other thread get discussed and finished.

Please keep checking this letter frequently as I'm constantly changing it as more points get identified and/or nailed down. Text that should end up in the letter is currently in italics

Please feel free to point out spelling mistakes or phrases that could be improved


Issues identified so far:

1. cost
A motorhome is a private vehicle, owned by private persons. Despite the relatively high price of motorhomes, not all motorhome owners are rich. Often a motorhome gets bought to enable families to spend weekends and holidays together on a budget and not as a luxury item. As such we are disappointed that the proposed test will be carried out at DOE centres and at DOE rates which are significantly more expensive than the equivalent NCT test for other private vehicles.

Private car:
NCT = € 50.00

Motorcaravan
< 3.5 tons fee 70.86 + VAT + cert 6.00 = € 91.74
> 3.5 tons fee 94.52 + VAT + cert 13.00 = € 127.37

We would therefore ask you to reconsider the pricing structure and bring it into line with the NCT test rate of 50 Euro. (Prices for the MOT test in the UK certainly are the same for private cars and motorcaravans)
Furthermore, the NCT issues a certificate and a disc for the window. The DOE does no such thing. There you get a statement which then has to be converted into a certificate at the local tax office. We would request that this be changed to the DOE test center issuing the valid certificate and disc in the first place to save additional cost and time and to enable us to continue using the motortax online system.

2. frequency
As motorhomes get used primarily on weekends and annual holidays only, the annual mileage is very low in comparison to other vehicles that get used daily or commercially. We therefore think that an annual test interval is excessive and not proportional to the use of the vehicle, also it would drive the cost up even more. Furthermore, Directive 2009/40/EC of the European Parliament of 6th May 2009, (to which you refer in yor test requirements) states on page L 141/16 Annex 1, Item 6 , that frequency of testing is every two years for vehicles for the carriage of passengers and with not more than 8 seats.
In light of this we would like to ask you to reconsider the proposed annual test (for older vehicles) and change it to / leave it at a bi-annual interval

3. glazing (item 4.3.4 of the draft proposal)
This shows that shoehorning motorcaravans into existing regulations presents a problem because the uniqueness of motorhomes isn't catered for in the existing test manuals.

The Vehicle Testing Manuals also state that where windscreens, side or rearwindows, are fitted with glazing material other than safety glass, the vehicleowner shall provide a certificate from the manufacturer or installer stating that the glazing material is not likely, if fractured, to produce fragments capable of causing severe cuts.
Issues have arisen in the past, where the markings affixed to the glazing werenot evident on examination by the vehicle tester, and it has proven difficult for owners to provide certification to the standards above, particularly in the case of vehicle manufacturers/converters that are no longer in business. In such instances it may be necessary for the vehicle to be re-glazed with material meeting the standards specified above.

This regulation fails to take account of the fact that most motorcaravans are only fitted with glass windows in the drivers cab and all other windows have been made from plastic materials for years. It also places an undue burden on the owner of the vehicle in having to obtain certificates for something that has been motorcaravan standard for decades. Furthermore it displays an ignorance of existing safety regulations that, quite frankly, coming from the Road Safety Authority, we find somewhat disappointing.
The Standard E 43R that gets mentioned in the manual has been standard for glass materials for decades, but has in 2003 been extended to plastic materials as well. Motorhomes from 2003 and younger should therefore have their E 43R marked plastic windows recognised automatically without the owner having to obtain any certificates whatsoever.
Futhermore, the E43R mark for plastic windows has an internationally recognised earlier equivalent in the "D" wave mark, see picture

old wave D-mark on left, E 43R mark on right

The "D" mark, consisting of a wave with a period of three and a capital "D" followed by a number is the German "Bauartgenehmigung" or type approval for safety glazing. This mark was introduced, overseen and controlled (until it was superseded by the E-mark) by the "Kraftfahrtbundesamt" (Federal Motor Transport Authority, short "KBA", homepage http://www.kba.de/EN/Home__en/homepage__node.html?__nnn=true) in Germany for a large number of european and international manufacturers of safety glazing materials.

We would therefore ask that you amend the test manual in order to recognise plastic glazing materials with the E 43R or the wave D mark automatically and remove the need for further certification for these.



4. LHD vans
Many of our vans are left hand drive and equipped with lights that dip to the wrong side. Most of our vans are also used mainly on the continent for holidays. New, correctly dipping light units for motorcaravans can be very expensive and in some case can't be obtained at all (depending on model and year). This is why some motorhome owners rely on so called "beam benders" to make their LHD lights RHD compliant.

According to the HGV test manual, Page 60 (actually page 126 of the PDF), "Headlamp Condition, Notes":

"Headlamp beam converters fitted to right hand dipping headlamps of vehciles which are mainly used on the continent, which effectively mask/deflect the beam are acceptable provided that the pass/fail criteria is met".


We would move that because of excessive cost for conversion / in some cases the inability of conversion to RHD headlamps and because our vehicles also get used on the contintent a lot, the acceptability of "beam benders" as outlined in the HGV manual should be extended to all LHD motorhomes, including those under and up to 3500 kg, in the new test manual.

A further concern in relation to LHD vehicles may be in the positioning of single rear foglights and/or reversing lights. As owners of LHD private cars will confirm, this isn't an issue in the NCT test. We would therefore hold that it should not become an issue in the motorcaraven test either.


5. ALKO chassis (this is a separate chassis, especially on low profile vans ...how will this be tested)
I have written a mail to ALKO headquarters, outlining the issue ...hopefully we will get a reply from their point of view
the reply has arrived, this looks to be a bit of a non-issue really, please see post #75 in the discussion thread for details

6. certificate (we would like a proper certificate and a disk for the window, like the NCT, wouldn't we?)
now incorporated into issue 1, cost

7. HGV test / general test criteria
campervans over 3.500kg rated weight would fall under the HGV test criteria. Now those criteria were written with heavy trucks in mind (with air brakes, special mirrors, different plates, etc)
most of the campers over 3.5 tons would have none of that as the are based on Sprinter/Ducato/Iveco chassis and just uprated from 3.5 to 3.85 ot 4.2 tons ...the test would need to reflect that.
Can we identify any procedures in the HGV manual that could possibly damage a motorhome ?

The majority of motorhomes is based on light commercial vehicles up to 3.5 tons. Some motorhomes however are based still on the same type of vehicle (a van basically) but in their case the chassis was upgraded to achieve gross vehicle weights between 3.5 and 5 tons, the majority again being between 3.5 and 4.0 tons. Under the proposed test regulations these uprated vans would fall into the HGV test category. Once again, there they would meet with test criteria designed with something else in mind and not applicable to what is common motorhome standard. A few glaring examples would be:
- plating: Motorcaravans carry a plate specifying weights, but not dimensions
- air brakes: Motorcaravans on van chassis usually have hydraulic brakes
- truck mirrors: once again, vans may have different mirrors.
These are just some examples that are obvious on a first reading of the HGV manual, closer inspection of the actual test procedure might quite likely bring some other issues to attention. Once again, the non motorhome-specific test criteria offer ample scope for a narrow minded tester to stick to the letter and deny a pass in the test and/or create a lot of hassle for the owner for things that have been recognised (and passable) standard in other countries for years. (How else would a brandnew 4 ton motorhome leave the factory without dimensions on the plate, for example?)
Other countries (Germany for example) have the threshold between LGV and HGV at 7.5 tons.
We would argue that in the case of motorcaravans all vehicles up to 7.5 tons should be tested according to the LGV test procedure, which is far more fitting for the type of vehicle that these motorcaravans are based on.


8. General concerns

Motorhomes come in many shapes and sizes, but they all have one thing in common: They are designed as vehicles for private use (not commercial use), primarily for the transportation of passengers (less than 8 seats) and they all have been more or less heavily adapted / fitted out / re-designed to offer temporary accomodation to those passengers.
The current draft does not envisage a specific test for motorcaravans but tries to shoehorn them into existing tests for commercial vehicles.
While a large percentage of motorcaravans is built on light goods vehicles chassis, the final product may have nothing in common with the base vehicle but the engine and the drivetrain, the body structure, chassis and the interior having been purpose-buildt as a motorhome.
During these conversions many of the original equimpent body and interior parts will have been replaced by specially adapted parts. Not all of these adaptations can be clearly matched with test criteria that were designed with something else in mind and we fear that there will be ample scope for a narrow minded tester to fail a motorcaravan on items that are standard (and type approved) equipment for this type of vehicle just because they don't match the description in the test manual.

Common examples that spring to mind would include modified seat bases that swivel and turn, seat belt anchor points that have been moved from their original position, specially built low slung chassis and carriers, tanks and other adaptations that aren't found on other vehicles.

On a factory built motorhome all these items would have had type approval at the time the motorhome was first registered. Due to the high price of motorhomes there is a large stock of older motorhomes still on the road. These motorhomes would have had type approval granted in European countries according to local laws before EU-wide type approvals (and markings) became accepted law. (see explanation for glazing above as an example)

There must be provisions made in the motorcaravan test to accept these old standards as fact without having to provide documentation for each and every single item.

It cannot be that a motorcaravan that is perfectly safe and servicable is denied a pass on a test and thus taken off the road just because some standard motorhome equipment that is fitted to thousands of motorhomes (like a swivel seat base for example) does not match with the test criteria even though it was initally approved for road use in a EU country and may even have passed several roadworthiness tests in other EU countries prior to import to Ireland.

Not only would that cause severe financial hardship to the owner of this motorhome, but it would also leave the RSA open to class action from the EU regulatory authorities.

A way must be found (as unbureaucratically as possible) that allows a simple pass for standard motorhome components in working condition while still being able to fail items that have clearly broken or are unsafe.




Header for the letter (will move up later)

Dear Madams and Sirs.

This letter is in reply to your consultation process on Roadworthiness Testing of Motor Caravans. It has been compiled by the users of the motorhomes and campervans forum on boards.ie (http://www.boards.ie/vbulletin/forumdisplay.php?f=884)

First of all, we would like to thank you for your invitation to this consultation process. Our motorhomes are dear to us, quite literally, as they represent a considerable investment even when second hand and somewhat older and we do welcome the idea of a roadworthiness test in principle, as it will help to safeguard our investments.

However, we have several points of concern with the proposed test procedures that we would like to raise with you:

peasant

righty -ho

seenashow the letter is pretty much finished, I've converted it into a word document and uploaded it here as an attachment.

check and see if it works for you or if it needs anything else doing

(my version of word is in German ...I hope this doesn't cause any issues)

do the pictures of the markings show?

does the quote from the RSA document show?

can someone run it through a spellchecker please ...German Word and English text don't spellcheck

EDIT: Just checked the document again here in work ...pictures do show, everything seems to work and I ran a spellcheck as well, so there shouldn't be too many mistakes left

UPDATE
User wonderworm was so kind as to go through the letter and suggest a somewhat more elegant style for some of my more brutal formulatations.
I'll work those suggestions off over the next day(s) or so and post a final version of the letter [2] when I'm done ..so you might want to hold off on sending what's there.

peasant

Ladies and gentlemen, the motorhome & campervans forum proudly presents:


THE FINISHED LETTER !

please see attachment

peasant

wording of the finished letter:

(format is slightly different due to copy and paste and the picture of the markings isn't showing either)

---

Vehicle Standards
Road Safety Authority
Moy Valley Business Park
Primrose Hill
Ballina
Co. Mayo

April 2010

Dear Sir/Madam.

This letter is in reply to your consultation process on Roadworthiness Testing of Motor Caravans. It has been compiled by the users of the motorhomes and campervans forum on boards.ie (http://www.boards.ie/vbulletin/forumdisplay.php?f=884)

First of all, we would like to thank you for your invitation to this consultation process. Our motorhomes and campers are dear to us, quite literally, as they represent a considerable investment even when second hand and somewhat older and we do welcome the idea of a roadworthiness test in principle, as it will help to safeguard our investments.

However, we have several points of concern with the proposed test procedures that we would like to raise with you:


Cost
A motorcaravan is a private vehicle, owned by private individuals. Despite the relatively high price of motorcaravans, the majority of owners purchase one to enable their families to spend weekends and holidays together on a budget. With this in mind we are disappointed that the proposed test will be carried out at DOE centres and at DOE rates which are significantly more expensive than the equivalent NCT test for other private vehicles.

Private car:
NCT = € 50.00

Motorcaravan:
<=3.5 t fee 70.86 + VAT + cert 6.00 = € 91.74
> 3.5 t fee 94.52 + VAT + cert 13.00 = € 127.37

We would therefore ask you to reconsider the pricing structure of this test and bring it into line with the NCT test rate of 50 Euro. (Prices for the MOT test in the UK for example are the same for private cars and motorcaravans)

Furthermore, as the current NCT for private cars issues a certificate and a disc for display on the vehicle, we request that the proposed test does something similar. We propose that the DOE test centre issues a valid certificate and disc as is the case in the NCT test centre, thereby allowing motorcaravan owners the facility to continue using the online motor tax system.


Frequency of test
As motorcaravans are used primarily on weekends and annual holidays, the annual mileage is very low in comparison to other classifications of vehicles that get used daily or commercially. We therefore think that an annual test interval is excessive and not proportional to the use of the vehicle.

Directive 2009/40/EC of the European Parliament of 6th May 2009, (to which you refer in your test requirements) states on page L 141/16 Annex 1, Item 6, that frequency of testing is every two years for vehicles for the carriage of passengers and with not more than 8 seats.

In light of this we would like to ask you to reconsider the proposed annual test (for older vehicles) and change it to / leave it at a bi-annual interval

Glazing (item 4.3.4 of the draft proposal)
This shows that the proposal to include motorcaravans in existing regulations presents a problem because the uniqueness of motorcaravans isn't catered for in the existing test manuals.
Quote from your consultation document:
The Vehicle Testing Manuals also state that where windscreens, side or rear windows, are fitted with glazing material other than safety glass, the vehicle owner shall provide a certificate from the manufacturer or installer stating that the glazing material is not likely, if fractured, to produce fragments capable of causing severe cuts.
Issues have arisen in the past, where the markings affixed to the glazing were not evident on examination by the vehicle tester, and it has proven difficult for owners to provide certification to the standards above, particularly in the case of vehicle manufacturers/converters that are no longer in business. In such instances it may be necessary for the vehicle to be re-glazed with material meeting the standards specified above.

This regulation fails to take account of the fact that most motorcaravans are only fitted with glass windows in the drivers cab and all other windows have been made from plastic materials for years. It also places an undue burden on the owner of the vehicle, as they will have to obtain certificates for something that has been motorcaravan standard for decades. Furthermore it displays an ignorance of existing safety regulations that, quite frankly, coming from the Road Safety Authority, we find somewhat disappointing.

The Standard E 43R mentioned in the manual has been standard for glass materials for decades, but has been extended in 2003 to plastic materials as well. Motorcaravans from 2003 and younger should therefore have their E 43R marked plastic windows recognised automatically without the owner having to obtain any certificates whatsoever.

Furthermore, the E43R mark for plastic windows has an internationally recognised earlier equivalent in the "D" wave mark, see picture

old wave D-mark on left, E 43R mark on right



The "D" mark, consisting of a wave with a period of three and a capital "D" followed by a number is the German "Bauartgenehmigung" or type approval for safety glazing. This mark was introduced, overseen and controlled (until it was superseded by the E-mark) by the "Kraftfahrtbundesamt" (Federal Motor Transport Authority, short "KBA",
homepage http://www.kba.de/EN/Home__en/homepa...tml?__nnn=true)
in Germany for a large number of European and international manufacturers of safety glazing materials.

We therefore ask that you amend the test manual in order to recognise plastic glazing materials with the E 43R or the wave D mark automatically and remove the need for further certification for these.



LHD vans
Many of our vans are left hand drive and equipped with lights that dip to the wrong side. Most of our vans are also used mainly on the continent for holidays. New, correctly dipping light units for motorcaravans can be very expensive and in some case can't be obtained at all (depending on model and year). This is why some owners rely on so called "beam benders" to make their LHD lights RHD compliant.

According to the HGV test manual, Page 60 (actually page 126 of the PDF), "Headlamp Condition, Notes":

"Headlamp beam converters fitted to right hand dipping headlamps of vehicles which are mainly used on the continent, which effectively mask/deflect the beam are acceptable provided that the pass/fail criteria is met".

We would move that because of excessive cost for conversion / in some cases the inability of conversion to RHD headlamps and because our vehicles also get used on the continent, the acceptability of "beam benders" as outlined in the HGV manual should be extended to all LHD motorcaravans, including those under and up to 3500 kg, in the new test manual.

A further concern in relation to LHD vehicles may be in the positioning of single rear foglights and/or reversing lights. As owners of LHD private cars will confirm, this isn't an issue in the NCT test. We would therefore hold that it should not become an issue in the motorcaravan test either.



HGV test / general test criteria
The majority of motorcaravans is based on light commercial vehicles up to 3.5 tonnes. Some however are based still on the same type of vehicle (a van basically) but in their case the chassis was upgraded to achieve gross vehicle weights between 3.5 and 5 tonnes, the majority again being between 3.5 and 4.0 tonnes. Under the proposed test regulations these uprated vans would fall into the HGV test category.

Once again, there they would meet with test criteria designed with something else in mind and not applicable to what is common motorcaravan standard. A few glaring examples would be:
- plating: Motorcaravans carry a plate specifying weights, but not dimensions
- air brakes: Motorcaravans on van chassis usually have hydraulic brakes
- truck mirrors: once again, vans may have different mirrors.

These are just some examples that are obvious on a first reading of the HGV manual; closer inspection of the actual test procedure might quite likely bring some other issues to the fore. Once again, the non motorcaravan-specific test criteria can create difficulties for a tester in that he has to stick to the letter and deny a pass in the test and/or create a burden of proof for the owner for items that have been recognised (and passable) standard in other countries for years. (How else would a brand-new 4 ton motorhome leave the factory without dimensions on the plate, for example?)
Other countries (Germany for example) have the threshold between LGV and HGV at 7.5 tons.
We would argue that in the case of motorcaravans all vehicles up to 7.5 tons should be tested according to the LGV test procedure, which is far more fitting for the type of vehicle that these motorcaravans are based on.


General concerns
Motorcaravans come in many shapes and sizes, but they all have one thing in common; They are designed as vehicles for private use (not commercial use), primarily for the transportation of passengers (less than 8 seats) and they all have been more or less heavily adapted / fitted out / re-designed to offer temporary accommodation to those passengers.
The current draft does not envisage a specific test for motorcaravans but tries to shoehorn them into existing tests for commercial vehicles.

While a large percentage of motorcaravans is built on light goods vehicles chassis, the final product may have nothing in common with the base vehicle but the engine and the drivetrain, the body structure, chassis and the interior having been purpose-built as a motorcaravan.
During these conversions many of the original equipment body and interior parts will have been replaced by specially adapted parts. Not all of these adaptations can be clearly matched with test criteria that were designed with something else in mind and we fear that, due to the proposed test being non motorcaravan-specific, there will be ample scope for a tester to fail a motorcaravan on items that are standard (and type approved) equipment for this type of vehicle just because they don't match the non-specific description in the test manual.

Common examples that spring to mind would include modified seat bases that swivel and turn, seat belt anchor points that have been moved from their original position, specially built low slung chassis and carriers, tanks and other adaptations that aren't found on other vehicles.

On a factory built motorcaravan all these items would have had type approval at the time it was first registered. Due to the high price of motorcaravans there is a large stock of older ones still on the road. These would have had type approval granted in European countries according to local laws before EU-wide type approvals (and markings) became accepted law. (see explanation for glazing above as an example)

There must be provisions made in the motorcaravan test to accept these old standards as fact without having to provide documentation for each and every single item.


It cannot be that a motorcaravan that is perfectly safe and serviceable is denied a pass on a test and thus taken off the road just because some standard motorcaravan equipment that is fitted to thousands of motorcaravans (like a swivel seat base for example) does not match with the test criteria even though it was initially approved for road use in a EU country and may even have passed several roadworthiness tests in other EU countries prior to import to Ireland.

Not only would that cause severe financial hardship to the owner of this motorcaravan, but it would also leave the RSA open to class action from the EU regulatory authorities.

A way must be found (as unbureaucratically as possible) that allows a simple pass for standard motorcaravan components in working condition while still being able to fail items that have clearly broken or are unsafe.


With kind regards,



Sender name


Sender address


Sender motorcaravan registration number